No, Poles doesn't "cover it". Anytime there is an opening for GM or HC (think assistant GM and coordinators now too) they must bring in minority candidates fir interviews. The only weird loophole I think was if it occurred outside this year end hiring cycle, like an in season hiring, may be exempt.
I think Detroit is the only teams penalized in past, in 2003 were fined 300k. Seahawks were almost gonna get penalized when they hired Carroll, but got some sweetheart deal with a token interview they gave to Frazier.
But in today's climate and the NFLs continued interest in the topic I'd think anyone slipping up could see draft pick fines and not just a measly 300k.